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In CCA 200431015, the Chief Counsel's Office has defined the circumstances under which an unenrolled return preparer is entitled to sign a Form 2848, Power of Attorney and Declaration of Representative, as a taxpayer's representative with regard to an offer-in-compromise based on doubt as to liability.
The Chief Counsel's Office explained that §10.7(c)(1)(viii) of Circular 230 - which provides that an individual who prepares and signs a taxpayer's tax return as the preparer, or who prepares a tax return but is not required (by the instructions to the tax return or regulations) to sign the tax return, may represent the taxpayer before revenue agents, customer service representatives, or similar officers and employees of the IRS during an examination of the taxable year...